HAAP: Schedule of modifications

The Inspector's changes correctly and appropriately reflect the findings of the Retail & Leisure Study 2008 but the changes will impact on the project finances and there is absolutely no evidence that the revised overall proposals are financially viable.

The original viability analysis, as presented in the submission copy of the HAAP contained a major error (omitting land assembly costs) and the plans for more offices are contrary to their own expert's advice. The changes may well impact the financials and an updated viability analysis is required.

Evidence:
The HAAP states: "This analysis adopts realistic and robust assumptions, including construction costs based on standard building indices and the project team's knowledge of comparable schemes, and takes into account the potential cost of land assembly. It also relates to a scheme that would help to meet the Council's aspirations for the AAP area. Broadly speaking, the viability analysis demonstrates that the proposed redevelopment of the Eldon Way Opportunity Site is currently financially viable".
So the HAAP recognises the financial analysis is marginal but states that land assembly costs are included. However, the actual, source Viability Assessment paper states land assembly costs are NOT included (as indeed they are not!). No evidence the plan is financially viable.
The revised HAAP designates Hockley as a prime location for the provision of new office space in the District. There is no evidence to support this proposal - recent demand for offices has been poor and in August 2013 the council approved a planning application to convert existing offices in a commercial property (Warren House), located in the village centre, into flats. Further, the letter dated Sept 2012 from GL Hearn (on the Evidence Base) confirms there is little demand: "Office development in Hockley would be seen as a secondary investment and as such it would be very difficult to secure private sector funding for any speculative office development in the short term and it is unlikely to be viable in any case. As a result of this weak demand profile, office provision in Hockley is limited at present. In summary, given the current economic climate and secondary nature of the Hockley office market it is unlikely that development would prove viable without significant cross subsidy from higher value uses or public sector support".
The existing industrial premises in Eldon Way currently provide a significant source of business to the adjacent shopping area. If demand for offices is low (as per the GL Hearn report), this trade will not be replaced and there will be a loss of business.

The revised wording dilutes the requirement for a Transport Assessment to "strategic planning applications". With the emphasis on smaller 'boutique' businesses, there is no longer any guarantee any such "strategic planning applications" will be made. There are therefore no effective proposals or evidence to deal with highways issues (Chapter 3, Policy 3) and the council has consistently misled residents and undertaken a U-turn on repeated commitments to undertake a Transport Assessment as part of the HAAP. Smaller developments may also mitigate against meaningful improvements. A clear commitment to a full transport assessment is required.

Evidence:
A Freedom of Information (FoI) response from RDC acknowledged Transport Assessments had been undertaken in Rochford & Rayleigh but refused to release them. What happened to them and why was one not undertaken for Hockley?
Another FoI response revealed work has started on assessing highways issues. The outcome of that work has never been made public - a RDC FoI response denied receiving any output from this work - and presumably kept by the external consultancy. What happened to it and why has it been suppressed? Residents should be able to view the work that RDC commissioned - what are they hiding?
The council has consistently mislead residents by repeatedly stating at every stage, highways issues would be included in the HAAP but, in fact, excluded them.
There is no evidence to support proposals to insert slip lane and widen pavement for 3 extra slip-lanes at the Spa roundabout are viable and have not been properly researched, despite previous promises. FoI responses show RDC's own experts have expressed reservations
Other problem areas such as the railway bridge and Eldon Way junction are not even mentioned.
Proposal to raise access to Woodlands Road likely to cause delays on main road and endanger pedestrians.
The B1013 was assessed many years ago (Sept 2008) by ECC Highways as nearing capacity but no updates despite much increased traffic volumes. Why haven't capacity updates been undertaken?
No Transport Assessment has been undertaken for Core Strategy (as well as the HAAP). A Traffic Assessment is required to ascertain the impact on Hockley of the 3,500 additional homes to be built across the District as part of the Core Strategy.
The council committed to produce a Transport SPD but has not done so.

The proposals will materially change the character of Hockley by demolishing around 2/3rd of the village centre. This change of character has not been consulted on (but responses to previous consultations show it is heavily opposed.) The scale of change is relatively huge but little benefit and none of the key issues resolved - a poor plan which will damage Hockley!